In 1995, Chalmers, after ten years’ experience with the Single European Act, wrote:

If his reading is correct, the European legal order remains far removed from being the ‘constitutional charter’ the ECJ has read into the EC Treaty. In light of the findings from the three case studies in this book, I will argue that Europe more than ever needs strong judges to whom cases may be referred not only through the workings of market forces but also by competent public interest groups. However, unlike Lord Denning, I do not believe that the shaping of the European legal order can be left in the hands of the judiciary alone. The case studies provide ample evidence of the wisdom of judges, both UK and European, and of how far the judiciary can go in pushing for greater rights and more effective remedies, thus amply demonstrating the benefits as well as the limits of judicial activism. UK and European judges do not behave like legislators; they are well aware of the role and function politics will and must play in the furtherance of the European project.